https://www.taxtmi.com/caselaws?id=463932 HC held reassessment under s.147 invalid where the AO had already examined the issue of income from sale of shares in the original scrutiny assessment; attempting to treat the same income as business income amounted to a prohibited change of opinion absent any new material. The record showed no fresh material justifying reopening, no addition under s.14A in the original order, and the only other reassessment addition was a negligible Rs.24,000; the court found it unnecessary to admit the appeal and confined reassessment issues to the three grounds recorded. en-us Mon, 28 Jan 2019 00:00:00 +0530 Mon, 22 Sep 2025 17:32:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463932 HC held reassessment under s.147 invalid where the AO had already examined the issue of income from sale of shares in the original scrutiny assessment; attempting to treat the same income as business income amounted to a prohibited change of opinion absent any new material. The record showed no fresh material justifying reopening, no addition under s.14A in the original order, and the only other reassessment addition was a negligible Rs.24,000; the court found it unnecessary to admit the appeal and confined reassessment issues to the three grounds recorded. Case-Laws Income Tax Mon, 28 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463932